David Keen writes to the Charity Commissioners

Cross-posted from:

Letter to Charity Commissioners about the Society of St. Stephen the Great, and the former SPCK bookshops

Thanks to David for this. As always, comments are welcome here; but please be sure to also post your comments on David’s original post.

Thank you — Phil Groom.

David writes:

With no reply from Mark Brewer after 2 weeks, I have re-sent the original letter from the 498 ‘We Support Dave Walker‘ Facebookers. I will also be putting the following letter in the post later today. I’m not really interested in who gets back to me first, I just want justice.

Re: St. Stephen the Great Charitable Trust (charity no. 1109008, registered 12/4/05, removed 8/8/07)
St. Stephen the Great (charity no 1119839, registered 27/6/07)
St. Stephen the Great Charitable Trust (subsidiary of St. Stephen the Great, registered 19.8.07)

Dear Charity Commissioners,

I have a number of concerns about the charities listed above, and would be grateful if you could look into them.

The St. Stephen the Great Charitable Trust (SSGCT) has not filed any accounts with you since March 2006, either in its original incarnation as a registered charity, or as a subsidiary of ‘St. Stephen the Great’ (SSG) SSGCT was removed from registration on 8.8.07 and re-registered as a subsidiary of SSG on 19.8.07. It is now over 30 months since any financial records have been submitted. In the meantime the company has attempted to file for bankruptcy in the USA, is subject to 30 claims through employment tribunals in the UK, and employees are reporting that pension contributions have not been kept up to date.

The claim for bankruptcy itself was thrown out by the US courts, on the basis that the main creditors were in the UK, and legal action was promptly begun against the principal SSG trustee for attempting to use the US courts to evade their responsibilities elsewhere.

Saint Stephen the Great is also the name of a trading company, registered at Companies House (Company No. 061105190), whose Directors are the same as the SSG charity Trustees. It was incorporated on 16.2.07 and as yet has filed no accounts, their last return was due in March 2008 and is now more than 7 months overdue.

SSGCT ran a chain of bookshops, which it acquired from the Society for Promoting Christian Knowledge (SPCK) in 2006. In June 2008 the Chairman of SSG and SSGCT emailed shop staff to inform them that:
“SSG (St Stephen the Great – limited liability company) has been terminated as the trading company to operate the bookshops formerly known as SPCK Bookshops…. The bookshops will now be operated by ENC Management Company”
ENC is listed on the Companies House website as Company Number FC028292, and it’s Directors and Secretary are the same 3 people as the St. Stephen the Great charity trustees, and the directors of the St. Stephen the Great trading company.

My concerns are as follows:
1. Your website states: Trustees of charities with income exceeding £10,000 in their last financial year are required to complete and submit an Annual Return and a copy of the trustees’ annual report and accounts. This must be done within 10 months of the end of the charity’s financial year. 

SSG/SSGCT has not done this. In view of the financial situation detailed above, financial transparency would seem to be vital, yet the latest accounts only cover 2005-6. As a private citizen I would be fined if my tax return was submitted more than 9 months after the end of the tax year, but this has now been 30 months and rising. What is happening, and what processes are being followed to make SSG/SSGCT publish its accounts? Many suppliers and staff remain unpaid, and there seem to be pension payments missing as well. It is vital that up to date accounts are published to enable these claims to be properly processed.

2. If the bookshops are now being run by ENC Management Company, which has no formal relationship with any of the SSG charities, then is there a proper process for the transfer of assets from a charity to a private company, and has this been followed?

3. A memo from one of the ENC Directors, Mr Phil Brewer, to shop staff in August 2008 stated: “ On all purchases of 10 GBP or more, offer a 2 GBP discount if a donation of 1 GBP or more is made. They must also fill out a gift aid form.” A scanned copy of this memo is attached, retrieved from https://spckssg.wordpress.com/2008/08/24/philip-brewer-says-immediately-post-this/

However, given that the chain is now being run by ENC Management Company (a registered company) and not SSG (a charity), then is it legitimate to claim gift aid on purchases? If not, what is the legal position of staff who are being asked to do this?

4. The memo also instructs staff (no.5) inform customers that ‘thirdspacebooks’ – a website set up to support the bookshops – ‘supports charity’. However, ordering books through the site (http://thirdspacebooks.com/) merely takes you to Amazon, and there is no indication on the site of which charities it supports.

5. The confusion of names does not help, nor does the fact that Third Space Books, in its photographs of the shops, shows them still trading under the name ‘SPCK’, a name SSG is not entitled to use.

My concern in this is as someone who has used these bookshops, and has become concerned about various aspects of the way this business is run. If you are not already looking into these irregularities, can I please ask you to do so as a matter of urgency. There are 30 former staff, and many more suppliers, who remain unpaid by this organisation, and financial transparency is essential to make sure that people receive what they are owed.

Yours sincerely
Rev David Keen

16 responses to “David Keen writes to the Charity Commissioners

  1. So if just a few of us write to the CC we might get rid of the Brewers?

  2. I’ve no idea, though I do get the feeling that nobody has already written to the charity commission (or indeed the taxman), which I find rather strange considering all that has happened. The principal trigger for me is discovering on the CC website that they’re 2 years late with their accounts, at the same time as I’m getting red letters from HMRC telling me I’m in the mire if I don’t get my finger out. I don’t know if Companies House ought to get a note too, as the SSG trading arm accounts are also late.

    Given all the other financial questions, if the CC can just manage to unearth the accounts then they may be doing a big service to a lot of people.

  3. The more people that write in, the more likely they are to take notice, I think. Here’s their online contact form

  4. There is a problem with the Dave Walker downloads. Comments are not available. If we were able to trawl those comments we would find some saying that SSG and all it’s aliases had been reported to the CC. We have to keep at it. I’m willing to do so.

  5. I’ve now written as well – via their online contact form – as follows:

    Dear Sir or Madam,

    I am writing to express my grave concern over the trading activities and fundraising practices of the Saint Stephen the Great Charitable Trust, originally registered under charity no. 1109008, registered 12/4/05, removed 8/8/07, and subsequently removed and re-registered as a subsidiary of Saint Stephen the Great, charity no 1119839.

    This organisation is running (or, to be more precise, ruining) the chain of bookshops once known as SPCK, but is running them under a number of other trading names, specifically Durham Cathederal [sic] Shop Management Company, Chichester Shop Management Company and ENC Management Company, as well as maintaining a website trading as Third Space Books.

    Shop staff have been instructed to offer customers discounts on sales in exchange for gift-aided donations. Surely such a procedure cannot be a legitimate fundraising method, especially as the sales are being made by the various trading companies but donations are being gathered on behalf of St Stephen the Great?

    Furthermore, all of these companies as well as the SSG charity are owned and operated by Messrs Philip and Mark Brewer, who recently attempted to declare the organisation bankrupt in the Texas, USA, Bankruptcy Courts. The case was dismissed by the Texas courts with prejudice as having been submitted in bad faith, and appears to have been an attempt to evade responsibilities here in the UK.

    I attach herewith scanned copies of the proprietor’s instructions to staff for your information. More information about the activities of this organisation may be found in the news blog, SPCK/SSG: News, Notes and Info, for which I am responsible:

    Your prompt attention to this matter would be appreciated, please, and I look forward to hearing from you soon.

    Thank you.

    Yours sincerely,

    Phil Groom

    Their automated acknowledgement page says that a response can be expected within 5 to 15 days. Watch this space…

  6. I’m going the same way – just have to retrieve one more document. Going e-mail and snail mail.

  7. I’m guessing the CC are busy people, like the rest of us, so if folk are going to write to them it will probably help to raise specific concerns, and make reference to the evidence which substantiates them.

    I’ve tried to ask for specific things to be looked into, because anyone trying to get to grips with this case from scratch is going to get very confused very quickly (!), so the clearer people’s letters can be the better.

  8. Folks, I have a question and a thought or suggestion:

    Question: David, do you want us to re-post this in our blogs? Is it too late to do so?

    Thought or suggestion: These blogs do a very good job of keeping this subject in the public eye. I’d imagine they are vital for that. However, have you given any thought to starting a private “let down your hair” group for ex-workers? The purpose of this would be to coordinate your various efforts in a venue that’s away from the public. For example (and I assume it’s the same there as here) if the TaxMan receives a letter from an anxious taxpayer about withholding, that’s one thing. If they receive a scattering of anxious letters, it may take them years to put 2 and 2 together and realize there’s a problem. They’re an entrenched bureaucracy. If they receive a “We, the Undersigned” letter signed by however many of you share the anxiety, my guess is that somebody will pay attention. Ditto the Pension Man, the Eggman, the Walrus, and whoever else you’re going to need to answer to or who needs to know about some discrepancy.

    By joining together privately, you can hammer out whatever you need to, decide who has the best penmanship, agree on wording and delivery methods, and generally form a united front.

    I hope you will continue to keep your friends and supporters updated, and I hope the blogging and comments will continue unabated. But if you were to set up such a group, you’d need to be pretty choosy about who got in. You could do it on Google or Yahoo and have it be by invitation only.

    Anyway, this is just a thought.


  9. Thank you David, great letter.
    Out of interest this is the last response I had from the CC – the more of us who protest the greater our chance of justice.

    St. Stephen the Great (1118939)

    I write further to your recent correspondence regarding St. Stephen the Great.

    Several interested parties have contacted the Commission to raise a variety of concerns about the bankruptcy proceedings in the U.S. Courts and the operation of the former SPCK bookshops by St. Stephen the Great.

    Whilst the information we have been provided with has been extremely useful, we are unfortunately not in possession of all relevant information that we require at this time. We have therefore taken steps to try and obtain this, including contacting the trustees of the charity for their comments, in order to further consider whether, and to what extent, there are any issues of concern that we need to become involved in.

    It may not be possible or appropriate for me to provide you with piecemeal updates about our ongoing consideration; however, I will let you know the outcome as soon as this is known.

    For clarity, I should explain that the Commission’s interest in this matter is in ensuring that the trustees are all aware of and acting within all of their relevant legal responsibilities, that they have and are providing adequate financial, budgetary and administrative control of the charity and its assets and that they have a clear plan as to how the current situation will be addressed.

    We are not able to become involved in any of the specific financial or employment issues that have arisen, on behalf of, or in connection with, any of the charity’s creditors or the bookshop staff.

    I will hopefully be in the position to update you on the outcome of our consideration in the near future; however, as I hope you will appreciate, there are a number of potentially complex issues that have been raised in this case which may take some time to resolve. In the meantime, if you have any queries, or would like to provide any further information, please contact me directly.

    For your information, I have included below links to some of our publications that appear to be relevant to the current circumstances:




    Yours sincerely

    Steve Barnett

    Senior Manager, Large Charities Division


  10. Thanks Annie. How recent is this? I think it warrants a standalone post, but I’d like to include the date, please…

  11. Phil, that letter was dated the 25th june this year.

  12. Thanks Annie – I’ll wait for a more recent response before posting, but that’s still very useful for reference. Let’s hope the “near future” Steve Barnett refers to comes fairly soon!!

  13. Thanks for all your support phil – its much appreciated!

  14. And thanks Annie for contacting the CC in the first place.

  15. Annie: reposting is up to you, though if folk are writing their own letters and reposting those then even better.

    Interesting reply: I wonder what sanctions the charity commissioners have? There’s also the invitation ‘to provide further information’….

    And it’s useful to have a name, perhaps if folk are writing letters it should be for the attention of Steve Barnett. Looks like the SSG file at the Charity Commissioners is bigger than I thought!

  16. Pingback: Charity Commission Replies: Formal Inquiry In Progress « SPCK/SSG: News, Notes & Info

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